Did you know that over 60% of listed buildings in England and Wales fall below an E rating on their Energy Performance Certificate (EPC)? According to Historic England, this stark figure highlights the tension between conservation rules and energy efficiency standards, leaving many property owners unsure where they stand.
Whether you're renovating, letting, or selling a listed property, understanding EPC requirements is essential. In this guide, we'll explore when EPCs are required, what exemptions exist, and how you can responsibly improve your building’s rating without compromising its character.
What Is an EPC?
An Energy Performance Certificate (EPC) indicates a property's energy efficiency, rated from A (most efficient) to G (least efficient). It's a legal requirement for most homes sold or rented in the UK and provides recommendations for improvements that could raise the score.
However, listed buildings are a special case - enter a world of exemptions and tailored advice.
You may have already had a new assessment on your property and wonder why your new EPC is worse than your old one.
EPC Requirements for Listed Buildings
Are Listed Buildings Exempt from Needing an EPC?
The short answer is: sometimes.
According to UK government guidance, listed buildings may be exempt from needing an EPC if compliance with energy efficiency improvements would unacceptably alter their character or appearance.
It’s not about whether your property is listed, but whether the recommended EPC upgrades would change its character. Each case is judged individually.
Common Misconceptions
“All listed buildings are exempt from EPCs.”
Not true. Only if energy upgrades would alter the building’s historic or architectural integrity can an exemption apply.
“You don’t need to do anything if it’s listed.”
You may still need an EPC to rent or sell the property unless an exemption applies—and even then, documentation is crucial.
MEES and the 2025 Deadline
The Minimum Energy Efficiency Standards (MEES) are tightening. By 2030, landlords will be legally required to reach a C rating on new tenancies.
That’s a major challenge for listed buildings. If your property is exempt due to heritage constraints, you must register the exemption on the PRS Exemptions Register.
What Can Be Done to Improve EPC Ratings for Listed Buildings?
It’s a myth that listed buildings are impossible to improve. You just need to approach it with nuance.
Sympathetic Measures
- Secondary glazing (removable, non-invasive)
- Draught-proofing doors and sash windows
- Roof insulation using breathable materials
- Internal wall insulation (with lime plaster)
- Efficient boilers and heating controls
- Low-energy lighting
Always check if you need Listed Building Consent before making changes.
How the Harpr Surveyors MEES Energy Report Helps

Before commissioning an EPC, it’s smart to know what measures can be implemented without risking a poor rating.
Harpr Surveyors offers a MEES Energy Report that helps identify allowable and effective upgrades before a formal EPC is undertaken.
This service can help you:
- Plan works that are conservation-friendly
- Maximise your EPC rating safely
- Avoid unnecessary legal issues
Case Study: Listed Cottage in St Austell
A Grade II listed cottage built in the 1700s had an EPC rating of F. After a MEES Energy Report, it implemented:
- Secondary glazing (removable units)
- Loft insulation using natural fibres
- LED lighting and heating controls
Result: Upgraded to a solid E rating - compliant with MEES and with no harm to the building’s features.
Check out this other Listed Building we supplied some Scale Plans for.
When You Must Have an EPC
| Situation | EPC Required? | Exemption Possible? |
|---|---|---|
| Selling a listed property | Usually yes | Only if EPC measures alter character |
| Letting a listed property | Yes | Register exemption if MEES threshold unmet |
| Renovating only | No | Not required if not selling/letting |
What Should You Do Next?
- Check your building’s listing with Historic England.
- Assess whether EPC measures would alter its character.
- Get a Harpr MEES Energy Report.
- Document everything if claiming an exemption.
Final Thoughts
Listed buildings deserve careful stewardship - but that doesn’t mean energy efficiency must be ignored. By understanding the EPC rules, taking advantage of tools like the Harpr MEES Energy Report, and working within conservation boundaries, you can future-proof your property without sacrificing heritage.
If you're unsure whether your listed building needs an EPC, get in touch with Harpr Surveyors for expert advice tailored to historic properties.
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